The direct answer
RoHS - the Restriction of Hazardous Substances Directive 2011/65/EU - limits ten substances in electrical and electronic equipment sold in the EU: lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, and four phthalates added by Directive (EU) 2015/863. Once a suitcase includes electronics - USB charging, a motor, lights - RoHS applies, and the proof is a laboratory report using the EN/IEC 62321 test series. Our Model 1338 report (No. S250827030001-1, September 2025) screened the non-metal material, and all ten substances came back not-detected, leading to the Certificate of Conformity (No. S250827030001-2).
What RoHS does
RoHS restricts specific hazardous substances in electrical and electronic equipment (EEE). The idea is simple: electronics contain metals, flame retardants and plasticizers that are hazardous in production and disposal, so the EU caps their concentration in each homogeneous material. Unlike REACH, which manages SVHC communication across all articles, RoHS is a hard restriction with defined limits - and it is one of the directives behind CE marking for EEE.
The ten substances in one table
|
Substance group |
Substances |
Limit |
|
Heavy metals |
Lead (Pb), Mercury (Hg), Hexavalent chromium (Cr VI) |
1000 mg/kg (0.1%) |
|
Heavy metal |
Cadmium (Cd) |
100 mg/kg (0.01%) |
|
Flame retardants |
Polybrominated biphenyls (PBBs), Polybrominated diphenyl ethers (PBDEs) |
1000 mg/kg (sum) |
|
Phthalates (since (EU) 2015/863) |
DEHP, BBP, DBP, DIBP |
1000 mg/kg each |
The four phthalates were added to Annex II in 2015 and became mandatory for most EEE in July 2019 - which is why "RoHS 10" is now the standard scope.
The test summary, read in one minute
|
Report element |
What it tells you |
|
Report No. S250827030001-1 |
Unique ID; the certificate cites the same number |
|
Sample: Multi-function trolley box, Model 1338 |
The exact tested product - same model as our EMC report |
|
Tested material: grey fabric (non-metal) |
The scope of this submission - non-metal material |
|
Standard: 2011/65/EU + (EU) 2015/863 |
RoHS 2 with the phthalate amendment |
|
Methods: EN 62321 series |
The harmonized test methods (equivalent to IEC 62321) |
|
Result |
All ten substances N.D. - pass |
|
Certificate No. S250827030001-2 |
The conformity conclusion based on the report |
Report vs certificate
The report is the laboratory evidence - every substance, limit, method and result line. The Certificate of Conformity is the summary conclusion. It carries the same honest note as our other certificates: it is based on a single evaluation of one sample, it does not imply an assessment of the whole production, and it does not permit use of the test lab's logo. The report proves the sample; production control keeps the sample representative.
What this report does NOT cover
Honest boundaries:
- It covers the non-metal material submitted - the grey fabric of Model 1338. Metal components and other non-metal materials are outside this submission and need their own scope (Article G5 explains the split).
- RoHS is EU. Other markets have their own electronics substance rules.
- RoHS is one directive among several. EMC (our E-series article), REACH (our F-series article) and other CE-relevant directives sit alongside it.
- One sample, one configuration. Change materials, suppliers or components and the evidence needs revisiting.
FAQ
What does RoHS stand for?
Restriction of Hazardous Substances - Directive 2011/65/EU, which limits ten substances in electrical and electronic equipment placed on the EU market.
Does RoHS apply to luggage?
Only to luggage with electronics. A purely mechanical suitcase is outside scope; once you add USB charging, lights, a motor or a scale, the electronics bring RoHS obligations.
What are the ten RoHS substances?
Lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, and four phthalates (DEHP, BBP, DBP, DIBP) added by Directive (EU) 2015/863.
What are the RoHS limits?
1000 mg/kg (0.1%) for most substances, 100 mg/kg (0.01%) for cadmium, and 1000 mg/kg for the summed PBB/PBDE and each phthalate.
Is a RoHS report the same as a REACH report?
No - RoHS is a hard restriction on ten substances in EEE; REACH manages SVHC communication across all articles. An electronic product in the EU may need both, plus EMC.
How do I know a factory's RoHS report is current?
Check the standard versions (the EN 62321 series with their amendment years), the sample and model, the date, and the certificate's report number. Article G8 is the full verification checklist.
About this report
The document behind this article is report No. S250827030001-1 with certificate No. S250827030001-2, covering the non-metal material of our Model 1338 multi-function trolley box - screened against all ten RoHS substances with every result below detection. We share the full report and certificate with buyers building EU programs. If you need to know which substance scope applies to your product's materials, send your component list to clkbusiness@clkluggage.com or WhatsApp +86-18879628221.